It’s not the size of the well pad, it’s the volume of emissions

I was unable to attend the COGCC meetings on Wednesday. There’s a frack happening on a well pad south of Silt (probably Ursa) and our air quality turned to crap. The air pollution from the emissions makes me sick so I have to stay indoors (or leave town). BTW, my recent DNA test results prove that BTEXS in oil & gas emissions do indeed make me sick but that’s all I’m going to say about that at this time.

RIFLE — It was at the end of a 2 ½ hour meeting when Garfield County Commissioner John Martin turned to the director of the Colorado Oil and Gas Conservation Commission, Matt Lepore, and delivered what could be considered a brief summary of the meeting. “You have a lot of work to do,” Martin said.

The meeting, hosted by Garfield County in Rifle Wednesday, was intended to gain feedback from local governments on the Western Slope on two recommendations being considered by COGCC.

Both recommendations are part of a larger series delivered by Gov. John Hickenlooper’s oil and gas taskforce earlier this year, and deal specifically with local government involvement in the oil and gas regulatory process.

Wednesday’s stop was one in a series COGCC is participating in to gain feedback before beginning the formal rule-making process this fall. The commission already participated in three meetings on the Front Range before Wednesday, and many of the points made by Western Slope leaders resembled points made at those previous meetings, Lepore said.

Specifically, the Lepore mentioned recommendation No. 17, which calls for the establishment of a process for increasing the role of local governments when an operator proposes a “large scale facility” in an urban mitigation area — which the COGCC defines as an area with 22 occupied buildings in a circle of 1,000 ft around a facility or if there’s a high occupancy building, such as a hospital, in that same area.

While the regulatory agency has defined what constitutes an urban mitigation area, a “large scale facility” has yet to be defined, and COGCC hopes to craft the definition based, in part, on some of the feedback gleaned from the meetings with local governments.

However, as many Western Slope leaders noted Wednesday, that is not necessarily an easy task. Some grappled with creating a clear-cut definition based on certain aspects, such as the number of wells or tanks, noting that both the scope of a proposed project and the location could factor into other ongoing issues including the impact on traffic.

Parachute Mayor Roy McClung mentioned that opinions on the size of a facility would likely vary depending on the stage of the development.

“When you’re drilling, that it is a large scale facility,” McClung said in making a point that the impacts are almost always greater during the drilling and completion phase of oil and gas extraction operations.

Those comments and others were consistent with ones made at previous meetings, Lepore said after the meeting, adding that there likely won’t be a singular factor used to determine a large scale facility, but one that considers different metrics.

Here’s a different metric. Instead of considering the number of wells and amount of acreage on a project, let’s look at the volume of pollution caused during and after the drilling and fracking stages.

For example, this is a relatively small (by comparison) WPX Energy well pad in the Garfield Creek Wildlife Area, south of New Castle. As you can see in the video, even in a closed loop drilling system as is used in Garfield Creek, significant VOC emissions are detected leaking from the tanks. [Take the Garfield County FLIR tour]

This is a producing well. There is no drilling or fracking going on. Nonetheless, constant, significant VOC emissions are detectable at all times. As I experience the deterioration of Silt’s air quality from last week to this week caused by one fracking job south of town, the evidence of massive VOC emissions spewing into the air we breathe is undeniable.

They are making this harder than it has to be. When we acknowledge that every oil & gas facility produces constant, significant VOC emissions 24 hours a day then as we consider Recommendation 17, collaboration between operators and local governments must be required for the location of ANY oil & gas facility in “urban mitigation areas,” defined by the COGCC “as an area with 22 occupied buildings in a circle of 1,000 ft around a facility or if there’s a high occupancy building, such as a hospital, in that same area.”

It’s not about the size of the well pad, it’s about the volume of emissions.

Establishing that definition will be essential to the greater recommendation, which would require an operator to offer local governments to weigh in before the operator selects a facility location.

While many of the leaders said they had good relationships with some of the current operators, they also generally agreed that establishing communication early in the process could help prevent some issues between communities and the operators.

The second recommendation from the task force calls for operators to register with local governments and require operators, at the government’s request, to submit information regarding drilling plans for the next five years.

The intention behind the recommendation was to provide drilling information that could be factored into a municipalities comprehensive plan. While those who spoke generally agreed that having that information could be broadly useful, the volatility in the energy industry combined with the evolutionary nature of comprehensive planning would make it near impossible to create a single and binding plan.

It would be difficult for many operators to give a one-year plan, let alone a five-year plan, said Jeff Comstock, natural resource director in Moffat County. While Comstock questioned the practicality of the recommendation, he like others said it would not hurt to have the information, and suggesting creating a tool to gauge the operator’s confidence in the plans …

Oh please. This is where the industry wants to have it both ways – and insults our collective intelligence in the process. They often compare the impacts of oil & gas facility projects to impacts from other major construction projects. Yet they don’t want to play by the same rules as any other major construction project. Any individual or businessperson that plans to open a business or begin a project, no matter how small (shed) or how large (road or building), is required to “collaborate” with the local government (which also applies to Recommendation #17).

Building contractors and real estate developers are subject to market volatility such as cost overrides, weather conditions, design modifications, etc., that affect the ability to predict the progress or outcome of any given project one year or five years down the road.

No individual or business owner can predict the future. We are all subject to “the evolutionary nature of comprehensive planning.” Why should the oil & gas industry be exempt from that process? Stuff happens, things change and when they do individuals and businesses, in most cases, are required to go back to the community planning department and advise them about any changes to the original approved project plan. That is how normal, responsible municipal government functions on a daily basis.

Recommendations 17 and 20 are toothless proposals. The fact that the industry is whining about them via their taxpayer-funded government surrogates proves that they consider themselves exempt from the rules and regulations that individuals and businesses in the rest of civilized society are required to follow.

One Comment on “It’s not the size of the well pad, it’s the volume of emissions”

Yes, they are utterly toothless recommendations; and they most definitely declared themselves,with their subsurface mineral rights, above any silly old comphehensive plan. The only states that successfully fight these frackers don’t have spit estate laws. John Martin completely controlled the language and direction of the discussion.like the industry shill he is.